Privacy Policy


Effective Date: June 13, 2025
Camino Strategy Group, California, USA

Camino Strategy Group (“Camino,” “we,” “our,” or “us”) is a professional services and consulting firm headquartered in California, committed to protecting the privacy and security of all personal information entrusted to us in the course of our operations. This Privacy Policy describes the categories of information we collect, our lawful basis for processing, and your rights under applicable law, including the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act of 2020 (CPRA), the California Constitution, and other applicable U.S. privacy statutes.

Camino Strategy Group is not a data broker. We do not sell personal data. We do not track consumers across devices or websites. We do not disclose information to third parties for profiling, advertising, or data monetization.

1. Covered Entities and Applicability

This Privacy Policy applies to:

  • All interactions with Camino Strategy Group via our website, email, client onboarding, consulting engagements, or other communications

  • Individuals whose information is submitted to Camino for lawful business purposes or due diligence

  • Business partners, prospective clients, and referral contacts

This Policy does not apply to third-party vendors, referral networks, or software platforms that operate independently from Camino and are governed by their own privacy policies.

This Policy is issued in compliance with California Civil Code § 1798.100 et seq., and the California Constitution’s Right to Privacy (Article I, Section 1).

2. Information We Collect (Limited and Purpose-Bound)

Camino collects minimal personal information, only where necessary to fulfill contractual, legal, or operational obligations.

A. Information You Provide Voluntarily

  • Full name and title

  • Business or organizational contact details (email, phone, business address)

  • Role, affiliation, and areas of professional focus

  • Communications and documentation provided to us in the course of services

  • Information submitted through our website, intake forms, email, or scheduling tools

B. Information We Automatically Collect (Minimal)

We do not deploy tracking technologies or ad pixels. The only automated information we collect is technical, non-personal data necessary for website security and performance:

  • Browser type and version

  • Device and operating system type

  • IP address (used for diagnostic and firewall purposes only)

  • Timestamp of visit and referring URLs

We do not use cookies for behavioral analytics, remarketing, or profiling. If functional cookies are used for site navigation or session protection, they do not collect personal data.

3. Lawful Basis and Use of Information

We collect and process personal information only when:

  • You have provided affirmative consent (e.g., filling out a form or scheduling a consultation)

  • It is necessary to perform or prepare for a contractual agreement (e.g., consulting services)

  • We are required to comply with a legal or regulatory obligation

  • We have a legitimate business interest that does not override your privacy rights

We use personal information strictly for:

  • Communicating with clients, partners, and prospective clients

  • Delivering advisory and strategic services

  • Maintaining compliance with contractual and legal requirements

  • Protecting Camino’s legal interests, website, and infrastructure

  • Managing internal operations such as invoicing, research, and reporting

We do not use personal information for automated decision-making, cross-context behavioral advertising, or resale.

4. Data Sharing and Third-Party Access

Camino does not share personal information with unrelated third parties. Limited disclosures may occur under the following conditions:

  • Vendors & Processors: We may engage secure third-party platforms (e.g., Google Workspace, Zoom, CRM tools) to assist with communication, file storage, or business operations. These providers are bound by confidentiality agreements and required to comply with California privacy law.

  • Legal Disclosure: We may disclose data in response to lawful subpoenas, court orders, or regulatory inquiries, provided that we take reasonable steps to limit the scope of disclosure and, when permitted, notify the data subject.

  • Corporate Contingency: In the event of a merger, acquisition, or restructuring, personal information may be transferred subject to contractual assurances and confidentiality restrictions.

Camino does not sell, rent, license, or otherwise share your data with marketers, advertisers, data brokers, or lead generation companies.

5. California Consumer Rights (CCPA/CPRA)

If you are a California resident, you are entitled to the following rights under California Civil Code § 1798:

  • Right to Know: You may request the categories and specific pieces of personal information we have collected.

  • Right to Delete: You may request deletion of your personal information, subject to exceptions for data required by law, contract, or legitimate business operations.

  • Right to Correct: You may request correction of inaccurate information we hold about you.

  • Right to Restrict Use of Sensitive Information: We do not collect sensitive personal information (SPI) as defined under CPRA.

  • Right to Non-Discrimination: We will not deny services, charge different prices, or alter the quality of services if you choose to exercise your privacy rights.

To make a request, contact contact@caminostrategygroup.com with the subject line Privacy Rights Request. Identity verification is required. We do not act on unverifiable or excessive requests and may deny requests that conflict with professional or legal obligations.

6. Data Retention and Destruction

We retain personal information only for as long as it is reasonably necessary to:

  • Fulfill the purpose for which it was collected

  • Meet legal, regulatory, or contractual obligations

  • Defend against claims or audits

Data is stored in encrypted cloud environments and periodically reviewed for relevance. When data is no longer required, it is securely deleted or anonymized in accordance with NIST and industry standards.

7. Data Security and Limitation of Liability

Camino maintains commercially reasonable administrative, physical, and technical safeguards in accordance with the California Data Breach Notification Law (Civil Code §§ 1798.29, 1798.82) and best practices under the NIST Cybersecurity Framework.

Security measures include:

  • Role-based access controls

  • Multi-factor authentication

  • Use of secure enterprise-grade platforms

  • Regular review of user permissions and system logs

Limitation of Liability:
While we take strong precautions, no system can be guaranteed secure. By using our services or website, you acknowledge and accept that Camino Strategy Group is not liable for third-party cyber intrusions, force majeure events, or access resulting from user-side security negligence.

8. No Waiver of Professional Privilege

Nothing in this Privacy Policy shall be interpreted to waive any applicable privilege or confidentiality protections under state or federal law, including protections related to consulting work product, confidential business information, or non-disclosure agreements in force.

9. Indemnification

By using our website or engaging with Camino Strategy Group, you agree to indemnify and hold harmless Camino, its officers, affiliates, and contractors from any and all claims, liabilities, damages, or costs (including attorney’s fees) arising from:

  • Misuse of information provided to Camino

  • Misrepresentation of your identity or authority to submit data

  • Violation of applicable laws through use of our services or communications

This clause is subject to the limitations imposed by California law.

10. Policy Updates

We reserve the right to revise this Privacy Policy at any time, with updates reflected by the “Effective Date” posted above. In the event of material changes to how we collect or use personal information, we will provide a clear notice on our website and/or contact affected parties as appropriate.

11. Contact Us

For questions, access requests, or complaints related to this Privacy Policy or Camino’s data practices, please contact:

Camino Strategy Group
Email: contact@caminostrategygroup.com
Subject Line: Privacy Policy Inquiry

We are committed to resolving all concerns in accordance with California law and professional business practices.